Official SFDOG Comment on GGNRA Dog Plan

By sally - Posted on 28 May 2011

SFDOG submitted an official public comment on the GGNRA DEIS for a new Dog Management Plan. It was hand delivered to the GGNRA at 3:45 pm on Friday, May 27, 2011. The DEIS is so poorly done it does not meet the standards required of it by NEPA law. The SFDOG Comment includes examples of the many problems with the DEIS, highlights the extraordinary level of bias against dogs in its assumptions and analysis, and argues that it is so fatally flawed that it cannot be fixed. SFDOG also has links to comments from other groups and individuals here.

A few highlights of the Official SFDOG Comment:

It is clear that the DEIS is a fatally flawed document. It does not provide the baseline or site-specific data needed to fairly evaluate the alternatives. Unsubstantiated claims and assumptions underlie most of the analysis of the alternatives. The No Action Alternative is unfairly analyzed, with assumption of non-compliance while all action alternatives assume compliance. The DEIS assumes there are no impacts unless dogs are present, ignoring impacts from people, natural predators, and other causes, and denying the context needed to evaluate fully and fairly whether restrictions on dogs will have beneficial impacts or not. It ignores impacts on recreation, people, and the surrounding communities (especially city parks). It is full of impacts that “might” or “could” occur, but contains little, if any, documented evidence that those impacts are actually occurring in the GGNRA. It includes the poison pill of a CBMS, which will change permanently management status in the GGNRA while denying the public the chance to comment on those changes.

GGNRA staff have demonstrated a profound bias against dog walking in the past. They cannot be the ones who evaluate the public comments submitted as part of this NEPA process. In particular, they cannot fairly evaluate criticisms of their own studies that are contained in this and other public comments. NPS must arrange for an independent review of the public comments and an independent review of how the DEIS must be changed in response to those comments.

The DEIS is so fatally flawed it cannot be fixed. The GGNRA must throw it out and start over, doing the baseline studies required of it and fairly evaluating impacts and alternatives. SFDOG encourages the development of an A+ Alternative, one that is based on the 1979 Pet Policy, and that returns the plover restriction areas to off-leash access (given the DEIS’ failure to prove any impact by dogs on plover populations or survival). In addition, areas in San Mateo that were not part of the 1979 Pet Policy but where off- and on-leash recreation has traditionally occurred, such as Sweeney Ridge, must allow that off- and on-leash recreation to continue. Similarly, off- and on-leash should be considered for all areas that become part of the GGNRA in the future, such as Rancho Corral de Tierra, especially where off- and on-leash recreation have traditionally been enjoyed.